7(1)(l)

FOIA

Closed-session meeting minutes not yet released under OMA Sec. 2.06

Read the full statute text on /statutes →

Jump to the 2 issues decided under this provision, with a drafting brief ↓

0 upheld (no violation found) · 1 rejected (violation found) · 2 closed / insufficient info / other, out of 3 documents.

Not legal advice, and not a per-exemption ruling — this reflects each document's overall disposition. See the FAQ disclaimer.

How the Public Access Counselor has treated 7(1)(l)

Section 7(1)(l) of FOIA exempts minutes of meetings closed to the public under the Open Meetings Act when the public body has not yet made them available for public inspection. The decisions address requests for closed session minutes and verbatim audio recordings, which remain confidential until the public body determines they no longer require confidential treatment and votes to release them.

The PAC has upheld denial where the records were still unreleased closed session material. A library properly withheld closed session minutes and a verbatim recording, and a school district properly withheld several years of closed session minutes that had not been voted for release. By contrast, audio recordings of open public meetings are not covered by this exemption. A housing authority violated FOIA by withholding open-meeting recordings as deliberative material, because verbatim records of public business in open session are public records subject to disclosure.

At a glance: 3 documents from 2017(1 binding opinion, 2 determination letters). Most often cited alongside: 7(1)(a) (Confidential under other federal or State law) (2); 7(1)(f) (Preliminary drafts, notes, and deliberative materials) (1).

Recurring issues

Whether a verbatim audio recording of a closed session may be withheld when it has not been released under the Open Meetings Act. (Closed-session minutes and recordings of an investigation)
Whether closed session minutes covering multiple years may be withheld when the public body has not voted to make them public. (School board closed session minutes over eight years)
Whether audio recordings of open public meetings are public records that must be disclosed rather than withheld as deliberative material. (Audio recordings of a housing authority board's public meetings)

Practical points

A request for closed session minutes or recordings is likely to be denied while the public body has not yet voted to release them for public inspection.
Audio recordings of a board's open meetings are treated as public records subject to disclosure, distinct from unreleased closed session records.
A public body withholding closed session records generally cites both the Open Meetings Act confidentiality provision and the corresponding FOIA exemption.

Summary drafted from the linked decisions and checked against them; read the decisions themselves before relying on it. Not legal advice.

All 3 documents citing 7(1)(l)

Issues decided under 7(1)(l)

Individual questions the Public Access Bureau decided under this provision, with the rule it applied, grouped by outcome. Extracted automatically from the letters; check each source letter.

2 issues across 2 determination letters:2 no violation.

Counts are per issue, not per letter, and come from automated extraction checked against sampled letters. Determination letters are not binding precedent.

Authorities the Bureau cites most on this issue

Ill. Att'y Gen. PAC Req. Rev. Ltr. 23562 cited 2 times
Ill. Att'y Gen. PAC Req. Rev. Ltr. 49629 cited 2 times

Drafting brief for an AI assistant

Copy this into your assistant to help draft a request, appeal, or challenge to a denial that turns on this issue. It carries the rules and decisions, not your facts: add those yourself. Machine-readable version: foia-7-1-l.json.

TOPIC: 5 ILCS 140/7(1)(l) - Closed-session meeting minutes not yet released under OMA Sec. 2.06
SOURCE: Illinois Attorney General Public Access Bureau decisions compiled at https://illinoisfoia.org/exemptions/7-1-l/
NOTE: Determination letters are not binding precedent; they show how the Bureau applies the law. Verify every decision against the source PDF before citing it.

NO VIOLATION (2):
- Closed session minutes exempt from FOIA disclosure
  Rule: Closed session minutes are exempt from disclosure under section 7(1)(l) of FOIA as long as the public body has not voted to make them available under section 2.06(f) of OMA.
  Decision: School board closed session minutes over eight years (non-binding determination letter, March 7, 2025) https://illinoisfoia.org/opinions/letter-85548/
- Closed session minutes exempt under FOIA
  Rule: Closed session minutes are exempt from disclosure until the public body makes them available under OMA section 2.06.
  Decision: Closed-session minutes and recordings of an investigation (non-binding determination letter, May 20, 2024) https://illinoisfoia.org/opinions/letter-81399/

MOST-CITED AUTHORITIES: Ill. Att'y Gen. PAC Req. Rev. Ltr. 23562; Ill. Att'y Gen. PAC Req. Rev. Ltr. 49629

TASK FOR THE ASSISTANT: Using only the decisions above, help draft a letter. Argue from the rule and cite the decision by name and date. Do not invent decisions.

No violation (2)

Closed session minutes exempt from FOIA disclosure
Rule: Closed session minutes are exempt from disclosure under section 7(1)(l) of FOIA as long as the public body has not voted to make them available under section 2.06(f) of OMA.
No violation School board closed session minutes over eight years · March 7, 2025
Closed session minutes exempt under FOIA
Rule: Closed session minutes are exempt from disclosure until the public body makes them available under OMA section 2.06.
No violation Closed-session minutes and recordings of an investigation · May 20, 2024